OSEC SYSTEMS

Modern Slavery & Human Trafficking Policy

Foreword

OSEC Systems recognises that modern slavery is a global concern, and we are taking steps to ensure that we have measures in place to combat human-trafficking and modern slavery in all its forms.

We take a zero-tolerance approach to modern slavery within our local operations, and our local and global supply-chains.

Introduction

The Modern Slavery Act 2015 came into force on 29 October 2015 and requires certain companies to report annually on the steps that they have taken during the financial year to ensure that slavery and human trafficking are not taking place in their own business, or in their supply chains.

Although OSEC Systems is not legally obligated to report annually on its modern slavery mitigations, it is important to us as both a business and as human beings to have a policy in place that helps tackle and eradicate these abhorrent practices.

This policy sets out Omniscient Secure Systems Ltd.’s position on modern slavery and human trafficking and provides guidance on what to do if you experience or witness either of these whilst working for, or providing services on behalf of, OSEC Systems.

Modern slavery is a crime and a violation of fundamental human rights. It has four criminal forms, these are slavery, servitude, forced labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another, to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.

Scope of this policy

This policy applies to all employees, and to those working for us or on our behalf in any capacity, including directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

All applicable persons are required to read, understand, and comply with this policy. It does not form part of any contract with us and may be amended at any time.

Failure of an employee to comply with this policy may result in disciplinary action in line with company policies. Any non-employee who breaches this policy may have their contract and/or services terminated with immediate effect.

Responsibility for the policy

The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Company Secretary has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Company Secretary.

How to raise a concern

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your Line Manager or the Company Secretary as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your Line Manager, but if circumstances make this inappropriate, please approach the Company Secretary. Alternatively, you can report the matter in confidence to the Managing Director. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your Line Manager or the Company Secretary for further guidance.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Company Secretary or Managing Director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Policy.

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process. For all other employees, training will be provided as necessary.

Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Signed:

Tom Dowling
Managing Director
October 2023